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ITA 1961 → ITA 2025Transfer Pricing

Section 92CA Section 184

Reference to Transfer Pricing Officer (TPO)

RetainedHigh - Initiates the dreaded dedicated TP scrutiny.

Quick Answer

Section 92CA of the Income Tax Act, 1961 (Reference to Transfer Pricing Officer (TPO)) corresponds to Section 184 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 92CA

Section 92CA of the 1961 Act sets out the rules on reference to transfer pricing officer (TPO). Allows the Assessing Officer to refer the computation of ALP to a specialized Transfer Pricing Officer.

Under the Income-tax Act, 2025 (effective 1st April 2026), Section 92CA is retained and renumbered as Section 184 of the Income-tax Act, 2025. Retained. Risk-assessment algorithms now auto-flag cases for compulsory TPO reference without human intervention.

The transition impact on Section 92CA is assessed as High. Initiates the dreaded dedicated TP scrutiny.

Old Law (ITA 1961)Ch: X

Sec 92CA

Provision Summary

Allows the Assessing Officer to refer the computation of ALP to a specialized Transfer Pricing Officer.

New Law (ITA 2025)Ch: XII

Sec 184

Provision Summary

Retained. Risk-assessment algorithms now auto-flag cases for compulsory TPO reference without human intervention.

Key Changes & Highlights

  • TPO proceedings are now entirely faceless.

Related Sections

Frequently Asked Questions

Which subject does Section 92CA of the 1961 Act cover?

Section 92CA of the Income Tax Act, 1961 covers reference to transfer pricing officer (TPO). Allows the Assessing Officer to refer the computation of ALP to a specialized Transfer Pricing Officer.

What is the new section number for Section 92CA under the Income-tax Act, 2025?

Section 92CA of the Income Tax Act, 1961 maps to Section 184 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Risk-assessment algorithms now auto-flag cases for compulsory TPO reference without human intervention.

How does the Income-tax Act, 2025 affect Section 92CA in practice?

The transition impact for Section 92CA is rated High. Initiates the dreaded dedicated TP scrutiny.

What is new about Section 92CA under the Income-tax Act, 2025?

TPO proceedings are now entirely faceless. These points are specific to Section 92CA (Reference to Transfer Pricing Officer (TPO)).

Disclaimer: This mapping of Section 92CA (Reference to Transfer Pricing Officer (TPO)) to Section 184 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 92CA is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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